Federal Energy Regulatory Commission is seeking comments in a notice of proposed rulemaking (NOPR) to approve updates to a North American Electric Reliability Corporation data and energy reliability standard that would include transmission planners as reporting entities and provide clarification of the reporting process and the data required for proper system analyses.
As proposed, NERC’s Demand and Energy Data Reliability Standard would consolidate five current modeling, data and analysis (MOD) standards into a single comprehensive standard, called MOD-031-1, according to TransmissionHub.
It specifically provides authority for applicable entities to collect demand, energy, and related data to support reliability studies and assessments and to enumerate the responsibilities and obligations of requestors and respondents of that data. In addition, it redefines the terms “demand side management“ and “total internal demand.”
Reporting requirements would be updated to include weather normalized annual peak hour actual demand data from the previous year and explanations of how demand-side management forecasts and peak demand forecasts compare to actual management and demand for the prior year.
The NOPR, issued Sept. 18, specifically requests input on the collection of data through mechanisms other than data requests and clarification on whether a planning coordinator or balancing authority that receives data “through alternative mechanisms” remains obligated to provide such data to a regional entity upon request.
NERC’s updated requirements titled R1, R2, and R3 reference the obtaining of data through data requests as follows:
· R1: Each planning coordinator or balancing authority that identifies a need for the collection of total internal demand, net energy for load, and demand side management data shall develop and issue a data request to the applicable entities in its area.
· R2: Each applicable entity identified in a data request shall provide the data requested by its planning coordinator or balancing authority in accordance with the data request issued pursuant to R1.
· R3: The planning coordinator or the balancing authority shall provide the data collected under R2 to the applicable regional entity within 75 calendar days of receiving a request for such data, unless otherwise agreed upon by the parties.
According to NERC, the language of R1 is intended to reflect that planning coordinators and balancing authorities may not need to collect data through a data request issued under the new reliability standard.
In the NOPR, FERC said it understood NERC’s explanation to mean that while a planning coordinator or balancing authority could collect forecast data under another arrangement, they retain the option to issue a R1 request if, for example, the data are not forthcoming through other means. FERC, however, would like clarification on its understanding of the R1 language.
An R1 request would establish the functional entities that may be required to provide data. Transmission planners have been added to the list of possible functional entities under the new standard and resource planners have been excluded.
NERC noted in its proposal that transmission planners were included because they collect and develop system modeling data, including actual forecast load, to evaluate grid expansion plans. Resource planners, on the other hand, do not prepare any of the data requested in the new standard.
Commenters have 60 days from publication of the NOPR in the Federal Register to reply to the request, and a spokesperson for NERC told TransmissionHub on Sept. 19 that staff members are reviewing the request and will respond as required.